Les Seagraves EarthLink, Inc.

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Les SeagravesEarthLink, Inc.
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Beyond Your Privacy Policy Developing a
Comprehensive Privacy Plan

• Les Seagraves, CIPP
• VP, Chief Privacy Officer Asst. General Counsel
• EarthLink, Inc.

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Your Policy Should Cover

• Everything you do with personal information and
  what choices customers have
• Helps to have External and Internal policies the
  same
• Plan for the future

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Policy is great, now what ?

• Everything else you do or say can become policy
• Everywhere you deal with personal information
  needs to be part of a plan
• Follow the data

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Following the Data

• Advertising
• Communicating to Non-Customers
• Sign Up/Purchase
• Using the Product or Service
• Communicating to Customers
• Customer Interaction
• Ending the Relationship

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Everything about Privacy should be

• Easy
• Obvious
• Consistent

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Website

• Collect information?
• What do you say about it at the time of
  collection? (Obvious)
• Choices? (Easy)
• What actually happens?
• Consistent with privacy policy?
• 3rd Party Links? (Obvious)

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Marketing

• Are there claims about information use? Should
  there be?
• Clear what information is required?
• Contests?

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Email to customers

• Big issue because of different internal groups
  and uses
• Effective Opt-out? (Easy)
• Surveys
• Categorize information easy and obvious

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Registration

• Account for every piece of information coming in
• Storage
• Paper records destruction

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Customer Service

• Real time interaction with a customer
• Need good rules for what and how information is
  collected and used
• Ask for MMN? password? (Consistent)
• Warnings to customers?
• Phishing?

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Public Relations

• PR and Managers need to understand the
  intricacies of your policy
• CEO speeches be careful
• Blogs

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Plan for a mess

• What happens during a crises?
• Are privacy rules still followed?
• Are they bent in the name of urgency?
• Practice scenarios over and over (Consistent)

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Questions?

• Les Seagraves
• les.seagraves_at_corp.earthlink.net